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identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d 1251, 1255 (11th Cir. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
dentiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. I1(b). Rule 1 1 uses an objective standard. Kaplan v. DaimlerChrysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe t
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan'. Daimleravysler, A.G., 331 F.3d I251, 1255 (11th ar. 2003). The analysis is whether "a reasonable attorney in like circumstances could believe tha
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
identiary support after a reasonable opportunity for further investigation or discovery. Fed. R. Civ. P. 11(b). Rule 11 uses an objective standard. Kaplan ! DaintlerChrysler, A.G., 331 F.3d 1251, .1255 (11th Cir. 2003). The analysis is whether "a reasonable • attorney in like circumstances could beli
On information and belief, they did not speak to any current or former personnel from the Office or the FBI who were familiar with the structure of the West Palm Beach Office or with Movant's role (or lack thereof) in the Epstein investigation. Had they done so, they would have learned that there were approximately 20 As
Entities connected to both Kaplan and the West Palm Beach Office

Jeffrey Epstein
PERSON
Department of Justice
ORGANIZATION
George W. Bush
PERSON
Prince Andrew
PERSON
Scarlett Johansson
PERSONLeon Black
PERSON
United States
LOCATION
Virginia Giuffre
PERSONFBI
ORGANIZATION
Michael Jackson
PERSON
Ghislaine Maxwell
PERSON
Michigan
LOCATION
Minnesota
LOCATION
Supreme Court
ORGANIZATIONthe Southern District
LOCATION
Prince Charles
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSON
Eric Trump
PERSON
Vladimir Putin
PERSON